Sister E. Jones-Bey v. Chen

Background

Sister E. Jones-Bey, who was proceeding without a lawyer and had permission to file without paying court fees, sued 57 defendants. The amended complaint alleged events involving the New York City Administration for Children’s Services, New York City police officers, family-court proceedings, a landlord or former landlord, private individuals, federal officials, and state officials. The allegations included removal of her children, reports to child-abuse authorities and police, entry into her home, alleged harm to her children, housing and identity-theft disputes, and family-court orders affecting custody. She sought money damages and various court orders, including an order returning a minor child to her custody.

The case had originally been filed in the Eastern District of Virginia and was transferred to the Southern District of New York after an amended complaint was filed. The court also discussed an earlier related proceeding in this court, No. 20-CV-9171, in which Judge Louis L. Stanton had dismissed or otherwise rejected many similar claims but had allowed Jones-Bey an opportunity to replead some claims.

Court’s analysis

The court applied the screening rules for complaints filed without prepayment of fees. Those rules require dismissal of claims that are frivolous, fail to state a legally sufficient claim, seek money from an immune defendant, or fall outside the court’s subject-matter jurisdiction. Although courts read filings by people without lawyers generously, those filings still must provide enough factual detail to make a claim plausible.

Child-custody and family-court claims. The court held that it could not intervene in Jones-Bey’s child-custody proceedings under the domestic-relations abstention doctrine. That doctrine generally prevents a federal district court from deciding custody matters or overturning state family-court orders when the issues can be fully and fairly decided in state court. The court also denied Jones-Bey’s request for a federal writ seeking the return of her minor son. It held that federal habeas law does not provide jurisdiction to challenge a state court’s child-custody decision.

Claims under 42 U.S.C. § 1983. Section 1983 allows claims for violations of federal rights by people acting under state law. The court dismissed claims against family-court referees and judges, and against United States District Judges Louis L. Stanton and Pamela K. Chen, because the complaint sought damages for official judicial actions and did not plausibly allege that they acted outside their judicial roles or authority. Those claims were barred by absolute judicial immunity.

The court dismissed claims against the United States and Attorney General Merrick Garland in his official capacity because sovereign immunity generally protects the federal government and federal officials sued officially unless immunity has been waived. It dismissed claims against the State of New York and Attorney General Letitia James in her official capacity because the state’s immunity under the Eleventh Amendment applied and had not been waived or removed by Congress.

The court dismissed claims against the Administration for Children’s Services, the New York City Police Department, the New York City Department of Finance, and the City of New York. It concluded that the city agencies could not be sued as separate entities and that the complaint did not state a sufficient claim against the City. The court also dismissed claims against the Administration for Children’s Services employees because the complaint did not provide facts showing that they personally engaged in conduct sufficiently extreme to violate Jones-Bey’s constitutional right to family integrity.

The court dismissed claims against the police officers because the complaint did not adequately describe how several officers were personally involved in violating Jones-Bey’s rights. It also held that Jones-Bey had no constitutional right to a police investigation of her complaints. Finally, it dismissed the section 1983 claims against private individuals because the complaint did not show that those individuals acted under state law.

State-law claims and jurisdiction. The court concluded that the complaint did not establish diversity jurisdiction over possible state-law claims. Diversity jurisdiction requires the parties to be citizens of different states and requires more than $75,000 to be at stake. Jones-Bey did not allege the citizenship or addresses of the parties, so the court could not determine whether the requirements were met.

Disposition

The court dismissed the amended complaint for failure to state a claim, for seeking relief from defendants immune from such relief, and as frivolous under the fee-screening statute. The court denied Jones-Bey’s request for a writ of habeas corpus. It granted Jones-Bey 30 days to replead only the state-law claims she sought to bring under diversity jurisdiction, requiring her to allege the parties’ different state citizenship at the time she filed the original complaint and a claim exceeding $75,000. The court kept the matter open until a civil judgment was entered and denied fee-free appeal status after certifying that an appeal would not be taken in good faith.